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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20138H3831999-10-25025 October 1999 Forwards Draft Model of Renewed License for Calvert Cliffs, Unit 2 to Illustrate How List of Minimum Requirements Could Be Incorporated Into License Condition ML20217M9991999-10-22022 October 1999 Forwards Response to NRC 990930 RAI Re Void Swelling Degradation Mechanism,Per License Renewal Application for Ccnpp,Units 1 & 2 ML20217M1721999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept Form Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates ML20212M2631999-10-0404 October 1999 Informs That Staff Concluded That Licensee Responses to GL 97-06 Provides Reasonable Assurance That Condition of Util SG Internals in Compliance with Current Licensing Bases for Calvert Cliffs Nuclear Power Plant ML20216J8671999-10-0101 October 1999 Forwards Rev 52 to QA Policy for Calvert Cliffs Nuclear Power Plant. Rev Accurately Presents Changes Made Since Previous Submittal,Necessary to Reflect Info & Analyses Submitted to NRC or Prepared,Per to NRC Requirements ML20212J7811999-09-30030 September 1999 Requests That Licensee Address Potential Aging Mgt Issue Re Effects of Void Swelling of Rv Internals by Making Plant Specific Commitment to Implement Focused age-related Degradation Insp for Evidence of Void Swelling in Future ML20212J5611999-09-29029 September 1999 Informs That on 990916,NRC Completed mid-cycle Plant Performance Review of Calvert Cliffs.No Areas in Which Util Performance Warranted Addl Insp Beyond Core Insp Program Identified.Historical Listing of Plant Issues,Encl ML20216H7831999-09-28028 September 1999 Forwards Addl Info Re NRC SER for Ccnpp,Units 1 & 2,per License Renewal Application ML20212D5361999-09-20020 September 1999 Forwards Rev 1 to Calculation CA04048, Fuel Handling Accident During Reconstitution, as Agreed During 990909 Telcon ML20212C1861999-09-15015 September 1999 Requests That NRC Complete Review of TR CED-387-P,Rev 00-P, Abb Critical Heat Flux Correlations for PWR Fuel, by 000201.Util Expects to Use ABB-NV Correlation for Current non-mixing Vane Fuel in Reload Analyses in 2000 for Ccnpp ML20212A2001999-09-0808 September 1999 Forwards Insp Repts 50-317/99-06 & 50-318/99-06.Two Violations Being Treated as Noncited Violations ML20211N8971999-09-0707 September 1999 Responds to Ltr to D Rathbun of NRC Dtd 990720,in Which Recipient Refers to Ltr from Wc Batton Expressing Support on Renewal Application of Baltimore Gas & Electric Co for Calvert Cliffs Plants ML20211H9841999-08-31031 August 1999 Provides Comments Re Data Entered in Rvid for Ccnpp,Units 1 2,per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211K3091999-08-27027 August 1999 Informs That During 990826 Telcon,L Briggs & B Bernie Made Arrangements for NRC to Inspect Licensed Operator Requalification Program at Calvert Cliffs Npp.Insp Planned for Wk of 991025 ML20211J1611999-08-17017 August 1999 Documents Bg&E Consultations with MD Dept of Natural Resources Re Potential Impacts to Chesapeake Bay Critical Area & Forest Interior Dwelling Bird Habitat,Per Ccnpp License Renewal.Telcons Ref Satisfy Consulting Requirement ML20210V1181999-08-17017 August 1999 Forwards Toxic Gases Calculations for Control Room Habitability,As Discussed During 990713 Telcon.Util Will Make Final Submittal for Toxic Gases After NRC Has Completed Review of ARCON96 ML20210T5061999-08-16016 August 1999 Forwards Rev 0 to Ccnpp COLR for Unit 2,Cycle 13, Per Plant TS 5.6.5 ML20210U2761999-08-13013 August 1999 Forwards Listed Info Re Guarantee of Payment of Deferred Premiums for Ccnpp,Units 1 & 2,IAW 10CFR140.21 Requirements ML20210S8101999-08-12012 August 1999 Forwards Application Requesting Renewal of License for Mv Seckens,License SOP-10369-2.Without Encl ML20210S8131999-08-12012 August 1999 Forwards Summary of Various Open Licensing Actions for Bg&E That Were Completed During Unit 2 Refueling Outage Ending 990506 ML20210S7901999-08-12012 August 1999 Forwards semi-annual Fitness for Duty Program Performance Data for Period of 990101-990630,IAW 10CFR36.71(d) ML20210Q1941999-08-11011 August 1999 Informs That Info Submitted in 981130 Application Re CEN-633-P,Rev 03-P,dtd Oct 1998,marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended ML20210N5881999-08-0606 August 1999 Forwards ISI Rept for Ccnpp,Unit 2,fulfilling Intentions & Requirements Stated in Program Plan & Commitment to Comply with ASME Code Section XI ISI Requirements ML20210N5471999-08-0505 August 1999 Requests That License SOP-10031-3,for DF Theders,Be Removed from Active Files for Ccnpp,Due to Individual Being Reassigned to Position No Longer Requiring License ML20210N5491999-08-0505 August 1999 Requests That License SOP-10371-2,for RW Scott,Be Renewed IAW 10CFR55.57.Individual Has Satisfactorily Discharged License Responsibilities Competently & Safely.Without Application ML20210N1291999-08-0505 August 1999 Forwards NRC Response to W Batton Ltr Expressing Support of Renewal Application for Calvert Cliffs Plants as Requested in Ltr ML20210N9291999-08-0404 August 1999 Forwards Clarification to Initial Response to Biennial Rept on Status of Decommissioning Funding,As Required by 10CFR50.75(f)(1) ML20211C0951999-07-30030 July 1999 Expresses Appreciation for Participation in Y2K Training & Tabletop Exercise Held on 990714 ML20211B5381999-07-30030 July 1999 Expresses Appreciation for Support in Y2K Training & Tabletop Exercise Held on 990714.Suggests Referral to NRC Y2K Web Site to View Issues & Lessons from Tabletop That Will Be Tracked by NRC ML20210J0741999-07-30030 July 1999 Expresses Appreciation for Participation in Y2K Training & Tabletop Exercise on 990714.Suggests Referral to NRC Y2K Web Site to View Issues & Lessons from Tabletop That Will Be Tracked by Nrc.Web Site Should Reflect Info within 2 Wks ML20211C3251999-07-30030 July 1999 Expresses Appreciation for Participation in Y2K Training & Tabletop Exercise Held on 990714 ML20210E4941999-07-23023 July 1999 Informs That 1999 Emergency Response Plan Exercise Objectives Is Scheduled for Wk of 991025.Exercise Scenario Will Test Integrated Capability & Major Portion of Elements Existing within Emergency Response Plan ML20210D0911999-07-22022 July 1999 Responds to to Chairman Jackson Referring to Ltr from New 7th Democratic Civic Club,Inc.Forwards Staff Response to W Batton,President of New 7th Democratic Civic Club,Inc ML20210C5011999-07-21021 July 1999 Informs That SL Walters,License OP-10096-3 & CC Zapp,License Number SOP-2188-9,have Been Reassigned within Organization & No Longer Require NRC License,Per 10CFR50.74(a).Removal of Subject Licenses from Active Files for Ccnpp,Requested ML20210A5021999-07-20020 July 1999 Responds to ,Expressing Support for Renewal of Operating Licenses for Calvert Cliffs Plant & to Concerns Re Lack of Specificity for License Renewal Regulations & Length of Time Set Aside for Public Comment ML20211N9101999-07-20020 July 1999 Forwards Correspondence Author Received from New 7th Democratic Club Civic,Inc Raising Some Serious Concerns About Renewal of Nuclear Reactor Licenses for Calvert Cliffs Power Plant ML20210C2681999-07-20020 July 1999 Forwards Certified Copy of Listed Nuclear Liability Policy Endorsement,Per 10CFR140.15(e) ML20210C8461999-07-19019 July 1999 Informs That CF Farrow,License OP-10648-1,will No Longer Be Employed with Bg&E,As of 990709,per 10CFR50.74(a).Removal of Subject License from Active Files for Ccnpp,Requested ML20209J5171999-07-16016 July 1999 Forwards Comments from Accuracy Review of License Renewal Application SER ML20210B7651999-07-15015 July 1999 Forwards SER Denying Licensee Proposed TS Amend Dtd 981120, to Delete TS Requirements for Tendon Surveillance & Reporting Because TS Requirements Duplication of Requirements in 10CFR50.55a.Notice of Denial Encl ML20209G2081999-07-13013 July 1999 Forwards Insp Repts 50-317/99-05 & 50-318/99-05 on 990509- 0626.No Violations Noted ML20210A6311999-07-0606 July 1999 Discusses Closure of TACs MA0532 & MA0533 Re Response to Requests for Addl Info to GL 92-01,rev1,suppl 1, Reactor Vessel Structural Integrity, for Plant,Units 1 & 2 ML20209C1391999-07-0202 July 1999 Forwards Responses to Open & Confirmatory Items Based on Review of SER for Bg&E Application for Renewal of Operating Licenses for Calvert Cliffs.Bg&E Intends to Forward Comments Based on Accuracy Verification in Near Future ML20210D1531999-06-30030 June 1999 Informs of Receipt of from New 7th Democratic Civic Club,Inc Expressing Support for License Renewal. Requests Consideration in Addressing Concerns & Recommendations ML20209B5781999-06-29029 June 1999 Submits Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML20210D1741999-06-24024 June 1999 Expresses Opinions on Renewal of Nuclear Reactor Licenses Re Plant & Support Renewal Application of Bg&E.Requests That NRC Revise Procedures to Allow Sufficient Time for Public to Review,Evaluate & Respond to Info ML20211H8431999-06-23023 June 1999 Ack Participation of Calvert Cliffs Nuclear Engineering Dept in NRC Cooperative Research Project with Univ of Virginia. Copy of Relevant Portion of NRC Cooperative Agreement with Univ of Virginia Encl ML20196C6831999-06-21021 June 1999 Discusses Proposed Alternative Submitted by Bg&E for Calvert Cliffs NPP to Requirements of 10CFR50.55a(g)(4) in Regard to Compliance with Latest Approved Edition of ASME Code,Section XI for Third Ten Year Insp Interval Beginning on 990701 ML20196C4291999-06-21021 June 1999 Forwards Rev to ERDS Data Point Library for Ccnpp,Unit 2,per 10CFR50,App E,Section VI.3.a.Table Provides Brief Summary of Changes ML20195J8271999-06-16016 June 1999 Ack Receipt of to Jackson,Chairman of NRC Re Environ Impacts of Increased Patuxtent River Complex Flight Operations on Ccnpp.Clarification & Correction of Listed Statement Found on Page Two,Provided 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217M9991999-10-22022 October 1999 Forwards Response to NRC 990930 RAI Re Void Swelling Degradation Mechanism,Per License Renewal Application for Ccnpp,Units 1 & 2 ML20216J8671999-10-0101 October 1999 Forwards Rev 52 to QA Policy for Calvert Cliffs Nuclear Power Plant. Rev Accurately Presents Changes Made Since Previous Submittal,Necessary to Reflect Info & Analyses Submitted to NRC or Prepared,Per to NRC Requirements ML20216H7831999-09-28028 September 1999 Forwards Addl Info Re NRC SER for Ccnpp,Units 1 & 2,per License Renewal Application ML20212D5361999-09-20020 September 1999 Forwards Rev 1 to Calculation CA04048, Fuel Handling Accident During Reconstitution, as Agreed During 990909 Telcon ML20212C1861999-09-15015 September 1999 Requests That NRC Complete Review of TR CED-387-P,Rev 00-P, Abb Critical Heat Flux Correlations for PWR Fuel, by 000201.Util Expects to Use ABB-NV Correlation for Current non-mixing Vane Fuel in Reload Analyses in 2000 for Ccnpp ML20211H9841999-08-31031 August 1999 Provides Comments Re Data Entered in Rvid for Ccnpp,Units 1 2,per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20210V1181999-08-17017 August 1999 Forwards Toxic Gases Calculations for Control Room Habitability,As Discussed During 990713 Telcon.Util Will Make Final Submittal for Toxic Gases After NRC Has Completed Review of ARCON96 ML20210T5061999-08-16016 August 1999 Forwards Rev 0 to Ccnpp COLR for Unit 2,Cycle 13, Per Plant TS 5.6.5 ML20210U2761999-08-13013 August 1999 Forwards Listed Info Re Guarantee of Payment of Deferred Premiums for Ccnpp,Units 1 & 2,IAW 10CFR140.21 Requirements ML20210S7901999-08-12012 August 1999 Forwards semi-annual Fitness for Duty Program Performance Data for Period of 990101-990630,IAW 10CFR36.71(d) ML20210S8131999-08-12012 August 1999 Forwards Summary of Various Open Licensing Actions for Bg&E That Were Completed During Unit 2 Refueling Outage Ending 990506 ML20210S8101999-08-12012 August 1999 Forwards Application Requesting Renewal of License for Mv Seckens,License SOP-10369-2.Without Encl ML20210N5881999-08-0606 August 1999 Forwards ISI Rept for Ccnpp,Unit 2,fulfilling Intentions & Requirements Stated in Program Plan & Commitment to Comply with ASME Code Section XI ISI Requirements ML20210N5491999-08-0505 August 1999 Requests That License SOP-10371-2,for RW Scott,Be Renewed IAW 10CFR55.57.Individual Has Satisfactorily Discharged License Responsibilities Competently & Safely.Without Application ML20210N5471999-08-0505 August 1999 Requests That License SOP-10031-3,for DF Theders,Be Removed from Active Files for Ccnpp,Due to Individual Being Reassigned to Position No Longer Requiring License ML20210N9291999-08-0404 August 1999 Forwards Clarification to Initial Response to Biennial Rept on Status of Decommissioning Funding,As Required by 10CFR50.75(f)(1) ML20210E4941999-07-23023 July 1999 Informs That 1999 Emergency Response Plan Exercise Objectives Is Scheduled for Wk of 991025.Exercise Scenario Will Test Integrated Capability & Major Portion of Elements Existing within Emergency Response Plan ML20210C5011999-07-21021 July 1999 Informs That SL Walters,License OP-10096-3 & CC Zapp,License Number SOP-2188-9,have Been Reassigned within Organization & No Longer Require NRC License,Per 10CFR50.74(a).Removal of Subject Licenses from Active Files for Ccnpp,Requested ML20211N9101999-07-20020 July 1999 Forwards Correspondence Author Received from New 7th Democratic Club Civic,Inc Raising Some Serious Concerns About Renewal of Nuclear Reactor Licenses for Calvert Cliffs Power Plant ML20210C2681999-07-20020 July 1999 Forwards Certified Copy of Listed Nuclear Liability Policy Endorsement,Per 10CFR140.15(e) ML20210C8461999-07-19019 July 1999 Informs That CF Farrow,License OP-10648-1,will No Longer Be Employed with Bg&E,As of 990709,per 10CFR50.74(a).Removal of Subject License from Active Files for Ccnpp,Requested ML20209J5171999-07-16016 July 1999 Forwards Comments from Accuracy Review of License Renewal Application SER ML20209C1391999-07-0202 July 1999 Forwards Responses to Open & Confirmatory Items Based on Review of SER for Bg&E Application for Renewal of Operating Licenses for Calvert Cliffs.Bg&E Intends to Forward Comments Based on Accuracy Verification in Near Future ML20210D1531999-06-30030 June 1999 Informs of Receipt of from New 7th Democratic Civic Club,Inc Expressing Support for License Renewal. Requests Consideration in Addressing Concerns & Recommendations ML20209B5781999-06-29029 June 1999 Submits Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML20210D1741999-06-24024 June 1999 Expresses Opinions on Renewal of Nuclear Reactor Licenses Re Plant & Support Renewal Application of Bg&E.Requests That NRC Revise Procedures to Allow Sufficient Time for Public to Review,Evaluate & Respond to Info ML20196C4291999-06-21021 June 1999 Forwards Rev to ERDS Data Point Library for Ccnpp,Unit 2,per 10CFR50,App E,Section VI.3.a.Table Provides Brief Summary of Changes ML20195J6591999-06-16016 June 1999 Submits Proposed Alternative to Requirements of 10CFR50.55a(g)(4) (Automatic Compliance with Latest Approved Edition of ASME Code Every 120 Months).Proposal Will Apply Third ten-year ISI Interval,Scheduled to Begin 990701 ML20207F0201999-06-0101 June 1999 Forwards Third Interval Inservice Insp Program Plan for Ccnpp,Units 1 & 2, for NRC Review.Plan Satisfies Commitment Contained in Licensee to NRC 05000317/LER-1999-002, Requests That Cover Page for LER 99-002,dtd 990525,be Corrected to Indicate Rept Is Submitted Per Requirements of 10CFR20.2201(b)1999-05-28028 May 1999 Requests That Cover Page for LER 99-002,dtd 990525,be Corrected to Indicate Rept Is Submitted Per Requirements of 10CFR20.2201(b) ML20195B3751999-05-25025 May 1999 Forwards ECCS Codes & Methods Rept, as Required by 10CFR50.46(a)(3)(ii) ML20195B2521999-05-25025 May 1999 Submits Response to RAI Re LAR for Tube Repair Using Leak Limiting Alloy 800 Sleeves for Ccnpp,Units 1 & 2.Test Repts Encl ML20195B2271999-05-24024 May 1999 Forwards Certified Copy of Nuclear Liability Policy NF-216, Endorsement 128 ML20206U3051999-05-19019 May 1999 Submits Written Rept as Required follow-up to Verbal Rept Given to NRC Regional Administrator on 990419 of SG Tube Insps Conducted,Cause of Tube Degradation & Corrective Measures Taken as Result of Insp Findings ML20206U8281999-05-18018 May 1999 Forwards Missing Pages C-30,C-31,C-114 & C-115 from 990319 Response to NRC RAI, Wind Tunnel Modeling of Calvert Cliffs NPP Cpp Project 94-1040. Complete Copy of 1985 Rept, Wind Flows & Dispersion Conditions of Calvert Cliffs, Encl ML20212G9751999-05-12012 May 1999 Forwards Draft write-up Re OI 16 for F Grubelich to Consider ML20206K6921999-05-10010 May 1999 Forwards Certified Copy of Listed Nuclear Liability Policy Endorsements,In Compliance with 10CFR140.15(e).Without Encl ML20206K1711999-05-0707 May 1999 Informs That on 990430 Util Filed Encl Articles of Share Exchange with Maryland Dept of Assessments & Taxation to Form Holding Company,Constellation Energy Group,Inc (Ceg). CEG Is Parent Company of Bg&E ML20206C7521999-04-29029 April 1999 Provides Rept of Number of Tubes Plugged in Calvert Cliffs Unit 2 SGs During Recently Completed Isi,As Required by Calvert Cliffs Unit 1,TS 5.6.9.a ML20212G9891999-04-28028 April 1999 Forwards Current Draft Response to Ci 3.3.2.2-1 to Be Used as Example for OI Vs License Condition Vs Commitment Situation ML20206C7271999-04-28028 April 1999 Forwards Occupational Radiation Exposure Repts for 1998, as Required by Units 1 & 2 Tech Specs 5.6.1 & 6.1 of Isfsi. Repts Contain Tabulation of Number of Station,Util & Other Personnel Receiving Exposures Greater than 100 Mrem ML20206C7211999-04-27027 April 1999 Forwards Addl Info Which Is Being Made Available in Encl Licensed Operators Fitness for Duty Questionnaire.Encl Specifics of Personal Info Are Withheld,Per 10CFR2.790 ML20212G9851999-04-26026 April 1999 Provides Proposed Response to OI 4.1.3-1 for B Elliott to Consider ML20206U6691999-04-26026 April 1999 Advises That Documents Re Operation of Calvert Cliffs Nuclear Power Plant Should Be Addressed to Listed Natl Marine Fisheries Svc Office ML20205F8851999-04-0202 April 1999 Provides First Annual Amend to Bg&E License Renewal Application for Ccnpp,Units 1 & 2,as Required by 10CFR54 ML20205J0691999-04-0202 April 1999 Forwards Response to NRC 990129 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20205G2971999-04-0101 April 1999 Requests That NRC Complete Review of Rev 0 to CENPD-396-P, Common Qualified Platform TR & Rev 0 to CE-CES-195-P, Software Program Manual for 'Common Q' Sys, by 990930 ML20205D7471999-03-30030 March 1999 Forwards Biennial Rept on Status of Decommissioning Funding, IAW 10CFR50.75(f)(1) ML20207G4391999-03-30030 March 1999 Responds to from Cl Miller,Requesting Assistance of FEMA in Addressing Concerns Received by NRC Involving Offsite Emergency Preparedness at Plant NPP ML20205C4091999-03-26026 March 1999 Submits Info Related to Scope,Risk Mgt & Summary of Risk for Performing Preventive Maintenance on P-13000-2 Unit Transformer Re License Amend 205 1999-09-28
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gz BA1.TIMORE
. GASAND ELECTRIC 1650 CALVERT CLIFFS PARKWAY e LUSBY, MARYLAND 20657-4702 Geomorc caen Samoa Vect Passiotwf m on m.ua Dmher 29,1992 He HonorableIvan Selin .
Chairman U. S. Nuclear Regulatory Comminion Washington,DC 20555
SUBJECT:
Succestions to Improve the Rerulatorv Process
Dear Chairman Selin:
Baltimore Gas and Electric Company is pleased to respond to your imitation to comment on areas where the regulatory process can be improved and generation costs can be reduced while the current high degree of safetyis maintained.
We recently wrote NUMARC describing three specific suggestions to improve the current regulatory
' process. A copy of that letter is enclosed. First, both NRC and nuclear industry must strive to revise the regulatory structure. It must become more effectively geared to actual performance and risk than the current programmatic, deterministic approach.
Second, there are several current programs - including security, containment testing, and reporting requirements - that are overly prescriptive and unnecessarily expensive. Rese can be immediately revised without degrading safety. Adc itionally, we encourage and support merging the maintenance and license renewal rules to avoid duplication of efforts.
Third, we encourage NRC to re-focus their enforcement of current regulation to emphasize safety-significant issues. NRC management must take strong and unambiguous actions to motivate their staffs to carefully determine the safety significance of issues they are working on. Pursuing
. programmatic details ofissues that have no safety significance is a wasteful diversion of public and industry resources which we can ill afford.
f Flog Finally, we have reviewed the letter you received from Mr. John C. Brons, President and Chief Operating Officer of New York Power Authority. It contains an F.xcellent discussion of how procurement practices have driven up operating and maintenance costs. We agree with every point that he makes. Industry and NRC must revisit the procurement arena and correct the problems he describes.
He general public and our customers know, or at least are again starting to concede, that generating electricity from nuclear power is technically and environmentally sou,nd. De quality of energy produced versus its impact on the environment - a lot for a little- should not become a lost opportunity. We are, however, concerned that the nuclear option may not remain fiscally sound. It is unfair for the public to lose the nuclear option. Rising nuclear operating costs are caused in part by the inability of NRC and industry to work togeth'er, assess regulatory " lessons-learned" and revise regulations as necessgrgu cpust ensure the public only_ pay _s the correct cost of nuclear power
- y 7 kM C h QM - @i. g,,;9 t h' 4
,- Chairman Selin December 29,1992 Page 2 through regulation that ensures safety by resoMng risk.significant issues without wasteful distractions.
3 We look forward to discussing our ideas with you either personally or through NUMARC. Should you have any questions regarding this matter, we will be pleased to discuss them sit you.
Very trulyyours, t
L GCC#MO/ dim
)
Enclosure cc: C. H. Poindexter Commissioner K. C. Rogers, hPC Commissioner J. R. Curtiss, NRC Commissioner F.J. Remick, hTC Commissioner G. DePlanque, hPC J. C. Brons, NYPA J. M. Taylor, NRC Document ControlDesk, NRC Nuclear Management and Resources Council D. A Brune, Esquire J. E. Silberg, Esquire R. A Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J. H. Walter, PSC
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cat.TIMOPtE GAS AND ELECTRIC 1650 OALVERT CLIFFS PARKWAY e LUSBY, MARYLAND 20657-4702 Gnomot C Catti, ca. v cs e..... .n im os aso-mo November 3,1992 Nuclear Management & Resources Council 1776 Eye Street, NW, Suite 300 Washington,DC 20006 24 %
SUBJECT:
Industry-wide Initiative to Reduce Nuclear Generation Costs Gentlemem Baltimore Gas and Electric Co=pany considers the issue of how to improve the regulatory process to reduce nuclear generation costs while at the same time maintaining the current high degree of safety vital. We greatly appreciate Chairman Selin's invitation to identify areas where economics can be achieved without appreciable detriment to safety. We strendy urge NRC to pursue actions in response to this initiative.
Our suggestions fallin three areas. Em, we should strive to establish a revised regulatory structure more effectively geared to actual performance and risk than the current deterministic, programmatic appteach. Properly conceived, we believe this offers the long. term hope for regaining the nuclear option's competitive advantage in the nation's energy strategy.
Second. we believe that there are several current programs which are unnecessarily prescriptive and expensive - security is a prime example - and which could be immediately revised without degrading safety. We strongly urge the Commiuion to move promptly on these issues to demonstrate the practicality of reasoned reductions in regulation, thereby reversing the long. standing trend of expanding regulation.
Hid, we encourage NRC to take strong and unambiguous actions to encourage its staff to execute current regulation with a constant emphasis on safety. Pursuit of prograrmnatic details without safety ,
signi5cance are an inappropriate a!!ocation of both the regulator's and the utility's resources. '
SHirlING TO PERFORMANCE. BASED OR RISK. BASED REGULATION l This is the area in Nch we feel the greatest economics can be achieved. "Ibe initial basis for regulatory review of licenses was a deterministic approach in which nearly every plausible scenario was. evaluated, all equipment involved in the plant response was scrutinized, and detailed .
programmatic controls were established to assure the reliability of these components. We can now do better. As the technology has matured, we have developed extensive operating experience to focus our attention on the truly risk.signi5 cant equipment. Probabilistic Risk Assessment has been established as a meaningful quantifier of risk. These tools have enabled us to recognize and resolve many issues not fully apparent at initial licensing. They have also created the means to eliminate or reduce regulation in areas where safety is not materially affected.
NUMARC .
November 3,1992 Page 2 .
Procurement .
The prime impact of a proposed shift to risk- and performance-based regulation is in procurement.
We have many components designated as safety-related (SR) which do not contribute measurably to overall plant risk. The additional pedigree required for SR parts imposes a huge expense which is only justiSed for the limited number of components which truly affect plant safety. Restoring the abnity to use commercial-grade parts in the non-essential applications would substantiaHy reduce costs. In many cases, it would also improve the availability of these systems by allowing the utility access to the whole range of suppliers rather than the very limited (and dwindling) number.who maintain the certi5 cation required for SR parts. A second aspect of the burden created by overly-restrictive designation of systems or components as SR is the quality assurance / quality control standard imposed on their installation. DetaUed procedural controls and oversight requirements add sigmHeantly to our expense in areas which are often marginal to safety.
SurveiUance Another area in which a risk-based approach could yield substantial bene 5ts is survealances. Given the hundreds of surveillance tests performed with successful results, there should be a performance-based methodology to easily change test intervals based on the trend of these results. The current regulatory process to amend surveillance periodicity is too cumbersome to aUow routine adjustments.
Modifying surveillance periodicity based on performance will lead to reduced resounes demands and shutdown or system out-of-service time devoted to testing. It should improve true safety system availability by leaving the equipment in service.
A long-term objective should be a Safety Goal quantifying an appropriate assurance of safety while empowering the licensee to select the appropriate method to acec=plish it. Because of the large potential savings involved through improvmg current deter:ninisticaUy-derived regulatory rules, BG&E is ready to devote signi5 cant resources in cooperation with the industry and NRC to move forward in this area.
i BfPROVEMDT OF CURRDT RULES We have reviewed SECY-92-263, " Staff Plans for Elimination of Requirements Marginal to Safety."
We strongly encourage the NRC to aggressively pursue rulemaking to reduce the regulatory burden of containment structure leakage testing procedures (Appendix J), Ere protection features (Appendix R) and features for post. accident combustible gas control contained in it. The following other examples iUustrate areas where we feel an opportunity exists to quickly attain results:
s Securitv ;
- For apprcximately the last twenty years, the securitf plan has been based on a specific tnrest concept. Has the NRC re-evaluated the credibility of the threat that the security plan is designed to address? Have actual security threats justi5ed the need for the current elaborate security plan? Do we need a paramilitary force or an enhanced industrial security force? A reduction in the postulated threat (which appears to be more suitable for a DOE weapons-grade plant) and commensurate reduction in stafEng and equipment could result in substantial annual savings. We wou!J be pleased to participate in a NUMARC. sponsored i effort to make speci5c recommendations regarding the relaxation of security requirements.
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( NUMARC
Page 3-l l Aeoendix 7 Containment Lenka re Testine 1
Our type A Conrainment Izakage Tests are perfonned roughly every thiny months. Over the remining life of our present licenses, we will perform about 21 more Tyx Atests.
Including set-up and restoration time, each test takes two-to-three days on critica, path at a replacement power cost of about $340,000 per day. The direct cost of performing the test is about $200,000. We believe that the demonstrated reliability of our containment justi5es reducing the fre3uency of this. test to once every six years. "Ihis could reduce the total number of remming tests from 21 to 7. These would represent an amidance of over j
$81/2 million with no appreciable reduction in safety. j i
l Renortine Recuirements ]
- We believe there is substantial economy in reducing the many bureaucratic requirements that have cropped up over the years. The recent NUMARC letter on Reporting Requirements is I an excellent compilation of the scope of the problem. 'Ibe cumulative effect of reducing these requirements should afford substantial savings.
IMPROVED DTORCEMDT OF CURRDT RULES Beyond the issue of the commitment and readiness of NRC management to institute change, we anticipate signi5 cant implementation difHeulties. Our own organizational experience shows that in I
addition to conceptual acceptance by management, there must be a parallel effort to revise the organization's culture. A well-conceived revision of regulation can be effectively nulli5ed if inspectors in the Seld or mid-level supervisors are not on board. Strong upper-echelon encouragement and clear incentives from management are necessary to accomp!Ish the desired results at the working level. The groundwork for this can be laid by continual reinforcement that safety impact is essentialin regulatory activities under the current rules.
While current enforcement policy makes distinctions between safety.signi5 cant and non. safety-signincant regulatory matters, there is often substantial effort consumed in review and discussion of many pure compliance concerns. Openness to change and innovation by the licensee is not always characteristic of NRC stati and Staff review of licensee internal process revisions, for example, can discourage change just through inertia. Aggressive management leadership can go far to eliminate these undesirable characteristics and thereby set the stage for effective implementation of new rules as they are adopted. :
f In summary BG&E considers it essential that the nuclear industry and NRC aggressively revise the current regulatory framework. 'Ibe long:-term vision must be established and energetically pursued.
Equally important, we must take immediate action to reduce those marginal requirements already identiSed. We must act now! This industry is slowly bleeding to death with our own and regulator in5uenced bureaucracy. A joint effort aimed at a healthy review of these initiatives can lead to enbnced safety by focusing our mutual efforts in less prescriptive and more rational areas.
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- November 3,1992 Page 4 , ,
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